• Airlines and industry groups are questioning EU plans to reward contrail avoidance under the ETS revision, arguing the science, verification methods and modelling tools are not yet robust enough and should not be used ahead of the Commission’s own non-CO2 review due by end-2027.
• Concerns focus on NEATS, the proposed modelling and verification system, which has not been validated against real-world operations; trial data is cited as showing significant gaps between modelled and actual fuel impacts, while key weather datasets are not yet integrated into airline flight planning systems.
• Operational constraints add further doubt, with contrail-avoidance routing dependent on air traffic control approval and limited by airspace capacity and coordination challenges, leading airlines to argue that incentives are premature until real-time feasibility is proven.

Airlines and trade groups are questioning whether the European Commission can credibly design a reward framework for contrail avoidance ahead of its planned review of aviation’s non-CO2 climate impacts, due by end-2027.

Concerns centre on the proposed sequencing of policy, with industry figures warning that a July 2026 ETS revision would effectively pre-empt the Commission’s own formal assessment of non-CO2 effects, including contrails.

At the core of the debate is NEATS, the modelling system being positioned as a key instrument for quantifying contrail impacts and verifying mitigation performance. Industry sources note the tool has not yet been validated against operational data, with verification processes described as limited to checking whether airlines have “used the tool in good faith”, rather than confirming measured climate outcomes.

Operational evidence is also being cited as a constraint. A4E member TUI has reportedly conducted more than 200 contrail-avoidance flights, with results indicating fuel penalties around 30 percent higher than desktop modelling estimates. Industry participants attribute the divergence to in-flight tactical adjustments and routing realities that simplified models fail to capture.

Early outputs from NEATS V3 are also understood to have shown material deviations from peer-reviewed science in estimating climate effects. Separately, the weather datasets underpinning the system are not currently integrated into commercial airline flight planning platforms, limiting their practical use in day-to-day operations.

Operational constraints complicate airline-led avoidance

Beyond modelling limitations, airlines point to structural constraints in execution. Contrail avoidance routing is not solely an airline decision, with air traffic control approval required for any deviation from filed flight paths.

Airspace capacity, ATC workload and the absence of real-time coordination between air navigation service providers are cited as practical barriers to consistent large-scale deployment. Industry stakeholders argue this raises questions over the fairness of rewarding airlines for outcomes they cannot fully control.

The operational challenge extends into flight planning workflows, where fuel optimisation, weather avoidance and network constraints are already tightly balanced. Integrating contrail avoidance into pre-tactical decision-making would require systems capable of reconciling multiple competing parameters in real time, something not yet embedded across airline operations.

Industry voices are instead urging a staged approach focused on building empirical understanding. This would involve deeper analysis of existing flight data and live trials assessing whether contrail avoidance can be executed reliably within operational constraints.

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